Department of Justice

Executive Office for Immigration Review

Thursday, July 7, 2011

EOIR Announces Latest Disciplinary Actions Under Rules of Professional Conduct
One Attorney Immediately Suspended; One Receives a Final Order

FALLS CHURCH, Va. - The Executive Office for Immigration Review (EOIR) has recently taken disciplinary action against three attorneys for violations of the Rules of Professional Conduct for immigration attorneys and representatives.

EOIR announces these disciplinary actions to inform the public about attorneys and representatives who are no longer authorized to represent clients before an immigration tribunal. These names will be added to the list of disciplined immigration attorneys and representatives, which is available here. The list includes links to immediate suspension orders, final orders, and reinstatement orders issued in each disciplinary case.

Disciplinary proceedings begin when the Office of the General Counsel of either EOIR or the Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services, files a Petition for Immediate Suspension and/or a Notice of Intent to Discipline with EOIR's Board of Immigration Appeals (BIA). The disciplinary action can result in the public censure, suspension, or expulsion of an attorney or representative before the immigration courts, the BIA, and DHS. Before a suspended or expelled attorney can resume the practice of law before the immigration courts, the BIA, or DHS, the BIA must reinstate that attorney.

EOIR has recently taken the following disciplinary actions:

Immediate Suspension

The BIA ordered the immediate suspension of the following attorney:

  • Manuel Angel Gonzalez: The Supreme Court of California suspended Mr. Gonzalez from the practice of law for 60 days for conduct involving lack of competence and failing to cooperate with a state bar investigation. The BIA granted the government's petition for immediate suspension on June 15, 2011, based on Mr. Gonzalez's 60-day suspension in California and pending final disposition of his case.

Final Order of Discipline

  • Errol Ivor Horwitz: A final order of June 16, 2011, suspends Mr. Horwitz from practice before immigration tribunals for 30 days, effective June 10, 2011, based on his 30-day suspension in California.


The Rules of Professional Conduct appear in Title 8 of the Code of Federal Regulations (8 C.F.R. '' 1003 and 1292). They include provisions specifying grounds for disciplinary action, requirements for receiving and investigating complaints, and procedures for conducting hearings. The rules also authorize the BIA to suspend immediately an attorney or representative who has been subject to disbarment, suspension or resignation with an admission of misconduct as imposed by a federal or state court, or who has been convicted of a serious crime, pending a summary proceeding and final sanction. The Rules of Professional Conduct are available at http://www.justice.gov/eoir/vll/fedreg/2000_2001/fr27jn00R.pdf and http://www.justice.gov/eoir/vll/fedreg/2008_2009/fr18dec08c.pdf.

Additional information about the Attorney Discipline Program can be found here and at http://www.justice.gov/eoir/press/09/AttorneyDisciplineFactSheet.pdf.

- EOIR -

The Executive Office for Immigration Review (EOIR) is an agency within the Department of Justice. Under delegated authority from the Attorney General, immigration judges and the Board of Immigration Appeals interpret and adjudicate immigration cases according to United States immigration laws. EOIR's immigration judges conduct administrative court proceedings in immigration courts located throughout the nation. They determine whether foreign-born individuals—whom the Department of Homeland Security charges with violating immigration law—should be ordered removed from the United States or should be granted relief from removal and be permitted to remain in this country. The Board of Immigration Appeals primarily reviews appeals of decisions by immigration judges. EOIR's Office of the Chief Administrative Hearing Officer adjudicates immigration-related employment cases. EOIR is committed to ensuring fairness in all of the cases it adjudicates.

Executive Office for Immigration Review

Updated August 31, 2015

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